Privacy Policy
1. An overview of data protection
General information
The following Privacy Policy will provide you with an easy to navigate overview of what will happen with your personal data when you visit our website cl-y.com. The term “personal data” comprises all data that can be used to personally identify you.
Data processing on this website
Who is the responsible party for the processing of data on this website (i.e. the “controller”)?
The data processing on this website is managed by the operator of the website, CLY Communication GmbH, whose contact information is available under section 3 “General information and mandatory information” below.
How do we process your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form or subscribing our newsletter.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed). This information is recorded automatically when you access this website.
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at <a href=”https://devowl.io/rcb/data-processing/” rel=”noreferrer” target=”_blank”>https://devowl.io/rcb/data-processing/</a>.
The legal bases for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data are used to enable you and us to communicate, share information, give support, send technical notices or administrative messages. Other data may be used to analyze your user patterns.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or deleted. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.
In particular, at any time you may exercise your rights:
- to obtain confirmation of the data processing performed by the Data Controller,
- to access to personal data,
- to obtain correction or deletion of the data or limitation of the processing that are the same,
- to object to processing (unless there is a legitimate reason prevailing compared to the one that gave rise to his request);
- to receive the personal data concerning you (data portability)
Please do not hesitate to contact us at any time under the address disclosed in section 3 “General information and mandatory information” if you have questions about this or any other data protection related issues.
Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.
2. Hosting and Content Delivery Networks (CDN)
External Hosting
This website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contact information, names, web page access, and other data generated through a web site.
In particular, our website is hosted on WordPress.com. The service provider is Aut O’Mattic A8C Ireland Ltd, a company based in Ireland, acting as Data Processor. Because Aut O’Mattic’s services are offered worldwide, the information that the host processes to provide the services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for the host, other members of our group of companies, or third-party data processors. When providing information to entities outside the EEA, the host takes appropriate measures to ensure that the recipient protects all personal information adequately in accordance with this Privacy Policy as required by applicable law.
At this link please find the privacy policy of the host: https://automattic.com/privacy
In order to guarantee processing in compliance with data protection regulations, we have concluded an data processing agreement with our host. At link link please find the Data Agreement Addendum: https://privacydotblog.files.wordpress.com/2018/05/dpa.pdf
3. General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations, in particular the General Data Protection Regulation (GDPR) – Regulation (EU) 2016/679, and this data protection notice.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This data protection notice explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.
We herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access.
Information about the responsible party (referred to as the “controller” in the GDPR)
The Data Controller on this website is:
CLY Communication GmbH
Brunnenstr. 166
10119 Berlin
Deutschland
phone number: +49 (30) 1208-44040
email: office(at)cl-y.com
Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. To do so, all you are required to do is sent us an informal notification via e-mail. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)
In the event that data are processed on the basis of art. 6 sect. 1 lit. E or F GDPR, you have the right to at any time object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis, on which any processing of data is based, please consult this data protection declaration. If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data, that outweigh your interests, rights and freedoms or if the purpose of the processing is the claiming, exercising or defence of legal entitlements (objection pursuant to art. 21 sect. 1 GDPR). If your personal data is being processed in order to engage in direct advertising, you have the right to at any time object to the processing of your affected personal data for the purposes of such advertising. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to art. 21 sect. 2 gdpr).
Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.
Right to data portability
You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
Information about, rectification and cancellation of data
Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or deleted. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at the address provided above.
Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided above. The right to demand restriction of processing applies in the following cases:
- In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
- If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
- If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.
4. Recording of data on this website
Cookies
In some instances, our website and its pages use so-called cookies. Cookies do not cause any damage to your computer and do not contain viruses. The purpose of cookies is to make our website more user friendly, effective and more secure. Cookies are small text files that are placed on your computer and stored by your browser.
Most of the cookies we use are so-called „session cookies“. They are automatically deleted after your leave our site. Other cookies will remain archived on your device until you delete them. These cookies enable us to recognise your browser the next time you visit our website.
You can adjust the settings of your browser to make sure that you are notified every time cookies are placed and to enable you to accept cookies only in specific cases or to exclude the acceptance of cookies for specific situations or in general and to activate the automatic deletion of cookies when you close your browser. If you deactivate cookies, the functions of this website may be limited.
Cookies that are required for the performance of the electronic communications transaction or to provide certain functions you want to use are stored on the basis of Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in storing cookies to ensure the technically error free and optimised provision of the operator’s services. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.
If other cookies (e.g. cookies for the analysis of your browsing patterns) should be stored, they are addressed separately in this data protection notice.
Server log files
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:
- The type and version of browser used
- The used operating system
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry
- The IP address
This data is not merged with other data sources.
This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.
Contact form
If you submit inquiries to us via our contact form, the personal data provided in the contact form (i.e. name, surname and email address) as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.
The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 Para. 1 lit. f GDPR) or on your agreement (Art. 6 Para. 1 lit. a GDPR) if this has been requested.
The information you have entered into the contact form shall remain with us until you ask us to delete the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g. after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in particular retention periods.
Email newsletter
If you subscribe our newsletters, we use the data required (i.e. email address) for the purpose to send you the newsletter on a regular basis. The sending of email newsletters takes place on the basis of your express consent in accordance with Art. 6, par. 1, lit. A, GDPR.
We use Mailchimp for the sending of newsletters and for this purpose the service provider is acting as Data Processor. This service provider is based in USA. At this link please find the privacy policy of the service provider applicable to our newletter subscribers and contact details for EEA, Swiss and UK residents and any other residents: https://mailchimp.com/legal/privacy
You can object to this use of your email address at any time by sending a message to the contact option described above or via the link provided for this purpose in the newsletter, without incurring any costs other than the transmission costs according to the basic rates.
You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the „Unsubscribe“ link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.
The data deposited with us for the purpose of subscribing, sending and receiving the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.
Social networks
CLY Communication is active on the social networks Facebook, Instagram and LinkedIn. CLY Communication website only provides links to our presence on the respective platforms. CLY Communication does not save any data relevant to data protection for this purpose.
5. Changes to the Privacy Policy
CLY Communication reserves the right to modify this privacy policy so that it is always complying to the current legal requirements. We recommend that you read our data protection notice regularly in order to stay up to date regarding the protection of the personal data that we collect.